Liwa Plastic Industries’ Complex - Orpic Project_Supplementary... · Liwa Plastic Industries’ Complex Additional Environmental & Social Information for Lenders Supplementary Social

Oman Oil Refineries and Petroleum Industries Co.

Sohar Refinery, PO Box: 282

Falaj Al Qabail, PC: 322, Sohar

Sultanate of Oman

Liwa Plastic Industries’ Complex

Additional Environmental & Social Information for Lenders

Supplementary Social Impact Assessment Report

14 January 2016

Supplementary SIA Report for LPIC

2 Final Draft 14 Jan. 2016

Issue and Revision

Rev. Document Description Date Revision Client

Prepared Checked Revised Approved

A

Supplementary

SIA Report

First draft 06/01/2016 HMR HMR n/a n/a

B Supplementary

SIA Report

Second draft

RHDHV 12/01/2016 RHDHV RHDHV n/a n/a

C

Supplementary

SIA Report

Third draft 13/01/2016 HMR HMR n/a n/a

D Supplementary

SIA Report Fourth draft 13/01/2016 RHDHV RHDHV n/a n/a

E

Supplementary

SIA Report

Final Draft;

released to

Lenders

14/01/2016 HMR/RHDHV RHDHV n/a n/a

This document has been prepared for the above titled Project and it should not be relied upon or used for any other Projec t without the prior written authority of HMR Environmental Engineer ing Consultants. HMR Environmental Engineer ing

Consultants accepts no responsibility or liabil ity for this document to any party other than th e client for whom it was commissioned.

HMR Environmental Engineering Consultants

P.O. Box: 1295, CPO Seeb, Postal Code: 111

Sultanate of Oman

Tel: (968) 24618800; Fax: (968) 24618811

Email: [email protected]

www.hmrenv.com

With specialist input to international standards:

Royal HaskoningDHV

Muscat, Dubai and UK Offices

Tel: +44 (0)20 7222 2115

Email: [email protected]

www.royalhaskoningdhv.com

http://www.hmrenv.com/



Contents

1. Introduction..................................................................................................................................... 5

1.1 Context .................................................................................................................................... 5

1.2 Site Visit ................................................................................................................................... 5

2. Socio-economic Baseline.................................................................................................................. 7

2.1 Introduction ............................................................................................................................. 7

2.2 Demographic Profile................................................................................................................. 7

2.3 Health Profile ........................................................................................................................... 7

2.4 Access to Water Resources....................................................................................................... 8

2.5 Education and Schools.............................................................................................................. 9

3. Additional Information on Social Risks and Impacts........................................................................ 10

3.1 Performance Standard 1: Assessment and Management of Environmental and Social Risks and

Impacts.............................................................................................................................................. 10

3.1.1 Pipeline and OGC Area Classification .............................................................................. 10

3.1.2 Sohar Industrial Area ...................................................................................................... 13

3.1.3 Potential Impacts on Local Communities in the Project Area........................................... 14

3.1.4 Outreach and Representation......................................................................................... 15

3.1.5 Grievance Mechanism and Monitoring ........................................................................... 16

3.2 Performance Standard 2: Labour and Working Conditions ...................................................... 16

3.2.2 Orpic’s Management of Workforce Providers and Recruitment Process.......................... 17

3.2.3 Labour Accommodation ................................................................................................. 18

3.3 Performance Standard 4: Community Health, Safety and Security .......................................... 20

3.4 Performance Standard 5: Land Acquisition and Involuntary Resettlement .............................. 23

3.4.2 Economic Displacement.................................................................................................. 25

3.5 Performance Standard 7: Indigenous Peoples........................................................................ 27

3.6 Performance Standard 8: Cultural Heritage ........................................................................... 29

4. Recommendations ......................................................................................................................... 31

Appendix A: Orpic Grievance Mechanism Process .............................................................................. 33

Appendix B: Site Security Plan............................................................................................................ 41

Appendix C: Royal Decree 52/2013 .................................................................................................... 42



Figure 1 An example representation of an area classification of Class 3 (provided by OGC) .................... 11

Figure 2: Proximity of Residences to Existing RoW at Al Jall.................................................................... 12

Figure 3: Buffer distances of houses and Mosque from Pipeline............................................................. 12

Figure 4: Al Jall Village Proximity to Pipeline .......................................................................................... 13

Figure 5: Sohar Industrial Area ............................................................................................................... 14

Figure 6 Orpic Meeting with ROP ........................................................................................................... 22

Figure 7 Clearly marked and available crossing points on pipeline..............................................................

Figure 8 Clearly visible signage along the pipeline ......................................................................................

Figure 9 BVS signage..................................................................................................................................

Figure 10 BVS using solar panels. ...............................................................................................................

Figure 11: Liwa City (Image from RD 52/2013) ....................................................................................... 25

Figure 12 Goats and domestic animals noted along the pipeline right-of-way ............................................

Figure 13 Al Jall Village .......................................................................................................................... 26

Figure 14: Pipeline crossing points (images from site visits and satellite image of a 4KM stretch of the

pipeline) ................................................................................................................................................ 28

Figure 15: Kashishat AL Melh Cemetery ................................................................................................ 30



1. Introduction

1.1 Context

The Social Impact Assessment (SIA) for the Liwa Plastics Industries Complex (LPIC) project (‘the Project’)

was developed in November 2015 as part of the process of fulfilling lenders’ requirements to attain

international standard reporting. This report provides additional information to support the original

Environmental and Social Impact Assessment (ESIA) process and resultant reports. The S upplementary

SIA Report has the following key objectives:

Substantiate the socio-economic baseline with additiona l information obtained through earlier stakeholder consultations and project site visits , and

Demonstrate further alignment with relevant International Finance Corporation (IFC)

Performance Standards (PS) that de fines a proponent’s responsibilities for managing their

environmental and social risks on a development project. (IFC, 2012). This report covers

information relating to PS 1, 2, 4, 5, 7 and 8.

1.2 Site Visit

Representatives from the group of Export Credit Agencies (ECA) and their advisors visited key locations

of the LPIC Project sites during the week of the 13 -- - 18 of December 2015. The site visit was

coordinated by Orpic and was also attended by their specialist environmental and social advisors. A

summary of the site visit is provided below. Details and outcomes from the visits and additional

stakeholder consultations are summarised in subsequent sections of this report.

• A tour around Fahud where there are existing facilities such as pumping stations and w here the

NGLE facility will be located. The site visit was coordinated by Oman Gas Company (OGC) who

hosted an introductory meeting including the provision of a Safety & Security brief and

information on their operational activities and corporate responsibility. The latter included a

number of social outreach initiatives. OGC will be operating the new pipeline to be constructed

between Fahud and Sohar for the Project (within an established Right of Way (RoW) that contains

multiple existing gas and water pipelines).

• Stakeholder consultation with the Governor, Sheikhs, Deputy Wali, representatives from the

Municipality and The Royal Oman Police (ROP) of North Batinah all in attendance. The morning

engagement session provided valuable insight on the socio-economic context for the project and

from the hosts, an acknowledgement of the citywide, regional and national economic benefits of

the Project.

• A visit to Orpic offices within the Sohar Industrial Port Area (SIP A), a driven tour around the

approach roads, boundary fence and some roads in and a round SIPA. This included the location of

key features of the LPIC Petrochemical Complex location (e.g. the cracker) and key transportation

access routes.

• A visit to the site of workers’ accommodation relating to the current Sohar Re finery Improvement

Project (SRIP). The objective was for the ECAs to see at first hand the typical working conditions at

workers’ camps in the Sohar area and to observe an example of the features and good living

conditions of such a facility. It is important to note that the ap pointed Engineering, Procurement



and Construction (EPC) contractors to the LPIC Project will be contractually obliged to provide

accommodation for workers in strict compliance with the European Bank for Reconstruction and

Development (EBRD) guidelines .

• A drive, in 4x4 vehicles along the RoW of the pipeline route. OGC and Orpic organised the drive to

observe a variety of features (e.g. formal crossing points) and ge ographical environments (e.g.

desert, wadi, mountainous, near industry and small settlements) through which the pipeline route

passes. The opportunity was taken to visit and have informal consultations with some of the local

residents of Al Jall village, where there are two houses close to the 50m safety zone either side of

the pipeline. Visiting this area provided a useful insight into on how OGC manages the relationship

between operating pipelines for national benefit while balancing the needs of the loca l

community in order to avoid, minimise and/or mitigate impacts from Project activities during

construction, testing/commissioning, operation and decommissioning. Furthermore, warning and

information signage marking the location and boundary of the RoW is clearly demarcated

ensuring safe and sufficient crossing-points for residents, communities, passage of passing

herders and vehicles

http://www.ebrd.com/downloads/about/sustainability/Workers_accomodation.pdf

http://www.ebrd.com/downloads/about/sustainability/Workers_accomodation.pdf



2. Socio-economic Baseline

2.1 Introduction

The detailed description of potentially affected villages and settlements for the pipeline, NGLE Plant and

the Petrochemical Complex in SIPA was prepared in November 2015. This section outlining a description

of socio-economic information serves to provide additional data and information to enhance the earlier

SIA Report and improve our understanding of the local operating environment. The information

presented was obtained through a review of publicly-available information and primary and secondary

data collected as a result of visits to the project area.

2.2 Demographic Profile

The Sultanate of Oman is currently experiencing the fastest population growth for at least 50 years

while it has one of the fastest-growing populations in the world. The growth rate is currently around 9%

per annum. From 2012 to 2013 alone, Oman’s population increased by more than 227,000 people. This

growth has been attributed to an increase in the birth rate and a decrease in deaths, partly due to an

improving healthcare system.1

The majority of the Sultanate ’s population falls into the 15-59 years of age category, with 23% of the

population being under 15 years old and 4% being over 60 years old. 77% of the population lives in

urban areas.

Based on the United Nations data, Oman’s population is largely concentrated in a few regions of the

country (i.e. In the Muscat Governorate and Batinah Region), which have high population densities. The

population density in Oman is approximately 14 people per km2, however, in the Al Batinah Region the

population density reaches approximately 62 people per km 2.

The main ethnic groups in the Sultanate of Oman include: Arabs, Baluchi, East African (Zanzibari), South

Asian (Indian, Pakistani, Bangladeshi).

Arabic is the official language of Oman, while English is widely spoken in many areas. Other languages

spoken in significant numbers are Swahili (due to the shared history of Oman and Zanzibar), Baluchi,

Urdu (spoken by Pakistanis and Indians), as well a s several distinct tribal languages in the Dhofar re gion

in southern Oman2.

2.3 Health Profile

As a result of considerable progress in economic and social development including the improved

provision of healthcare over the years, the Sultanate has achieved a life expectancy of over 76 years. Life

expectancy increased for both sexes by four years over the period of 2000 – 2012 which is a positive

improvement. This figure compares to the World Health Organisation (WHO) regional (Middle East)

average increase of life expectancy by three years in the same period.

1 United Nations World Population Prospects, 2015

2 Omani National Centre for International Learning, 2015



The number of live births is 74,300 per annum. The latest WHO health indicators show a significant

reduction in mortality, especially childhood mortality in the last 12 years. The main causes of infant

mortality (children under five years of age) in the Sultanate of Oman are: premature births, birth

asphyxia, injuries and acute respiratory infections. Child mortality cases caused by malaria or diarrh oea

are low, which is in line with other high income countries with the similar GDP level .

The leading cases of mortality among adults in the country among men are: raised blood pressure (32%),

diabetes (10%), stroke (10%), acute respiratory infections (6%). Among women, the leading reasons are:

raised blood pressure (29%), obesity (25%), diabetes (10%).3

The Ministry of Health of Oman does not collect and publ ish detailed information on the types of

prevalent health issues in the governorates, and therefore the above information was collected from the

WHO database which provides data at only country level.

As the Ministry of Health of the Sultanate of Oman does not collect information on the health profile in

governorates, such information was not available. To satisfy the applicable international standards

requirements (2012 IFC PS1 and Equator Principles III), ORPIC will collect socio-economic baseline data

locally, as part of the household survey to be carried out as a condition to first disbursement4. The

household survey in the project area will help to understand the health and livelihood profile of local

communities, and will enable ORPIC and its Lenders to identify the key parameters and monitor them

throughout the life of the project to ascertain how the Project is impacting upon lives of local residents.

There are over 450 beds/places for patients spread among five main hospitals located in the Al Batinah

Governorate, with the majority of beds (380) being located in the Sohar Hospital. More details on the

available health facilities in the project area can be found on page 20 of the earlier SIA prepared in

November 2015.

2.4 Access to Water Resources

One of the important water resources factors in this largely arid country is a lack of water, and security

of its supply in terms of both quantity and quality. Much of the Sultanate’s water needs are covered by

desalinated water, which although costly, is more secure and reliable. There are a number of

desalination plants distributed geographically over the Sultanate depending on the water demand; the

main desalination plants are located in Ghubra, Barka, Sohar and Sur. The Sohar desalination plant

supplies Al Batinah North Governorate and Al Buraimi Governorate.

In order to meet the increasing potable water needs across the Sultanate, Oman Power and Water

Procurement Company, the sole procurer of all new electricity generation and co -located water

desalination capacity in the Sultanate, has two major water schemes underway at Sohar and Barka on Oman’s Batinah coast. The Barka Independent Water Project (IWP ), with a contracted desalination

capacity of 281,000 cubic metres per day (61.8 million imperial gallons per day MIGD), will be the larger

of the two schemes. The Sohar IWP, on the other hand, will be sized at 250,000 cubic metres per day

(55.0 MIGD) of desalination capacity.

3 WHO Statistical Profile of Oman, published January 2015

4 See more details on the survey in the Recommendations section.



An increase in salinity of both soils and groundwater systems along the coastal strip of Al -Batinah has

affected local farmers in terms of crop selection and, therefore, farm profitability. More information on

water resources in the project area can be found in the earlier SIA prepared in November 2015.

2.5 Education and Schools

As of 2013, the adult literacy rate in Oman was 87%, with 97% of children being enrolled in primary

schools. The literacy levels are nearly similar between men and women which is a good indicator of girls’

attendance in schools at the earlier age. There are 175 Government schools with over 101,000 students

and 64 private schools with 10,400 students in the Al Batinah North Governorate.



3. Additional Information on Social Risks and Impacts

3.1 Performance Standard 1: A ssessment and Management of Environmental and Social Risks and

Impacts

This section further evaluates social risks and potential impacts, management and the monitoring

mechanism for the LPIC Project. Orpic has adopted a mitigation hierarchy to anticipate and avoid, or

where avoidance is not possible, minimise risks and impacts to workers and Affected Communities .

Where residual impacts remain, appropriate compensation/offsetting will be considered. This section

addresses the following aspects:

OGC Area Classification considering population densities and Affected Communities in the

vicinity of the existing pipeline RoW;

Outreach and Representation Programmes with potentially Affected Communities;

Grievance Mechanism and Monitoring.

3.1.1 Pipeline and OGC Area Classification

OGC was established in August 2000 as a closed joint stock company between the Government of Oman, represented by the Ministry of Oil & Gas holding 80% of the shares , and the Oman Oil Company

holding the remaining 20%. Royal Decree No. 78/2000 has granted the Company concession rights for

duration of 27 years to own, construct, maintain and operate natural gas facilities in the Sultanate of

Oman. During 2013, OGC was acquired in its entirety (100%) by Oman Oil Company.

OGC has adopted The American Society of Mechanical Engineers ( ASME) B31.8 guidelines for area

classification. ASME B31.8 is the most widely used Code for the design, operation, maintenance, and

repair of natural gas distribution and transmission pipelines . Four different class locations have been

established, each defined by the number of buildings and population density within specific distances.

The class location unit is an area that extends 200 met res (m) on either side of the centreline of any

continuous pipeline greater than 1.6 kilometres (km) in length. The number of buildings in the class

location unit determines the classification. For the purposes of this procedure, each separate dwelling

unit in a multiple dwelling unit building is counted as a separate building intended for human occupancy .

Class Location 1: any 1.6km section of line that has ten or fewer buildings intended for human

occupancy. This is intended to reflect areas such as wasteland , deserts, mountains, farmland

and sparsely populated areas.

Class Location 2: any 1.6km section of line with more than ten but less than 46 buildings intended for human occupancy.

Class Location 3: any 1.6 km section of line with 46 or more buildings inte nded for human

occupancy (illustrated in Figure 1).

Class Location 4: includes areas where multi-story buildings of four or more floors are prevalent,

where traffic is heavy and where there are numerous underground utilities.

OGC has used this Code and method of classification in order to identify and evaluate the social risks and

impacts along the existing pipeline. The area classification is updated on an annual basis using an



integrated GIS system. OGC updates the GIS system through site visits and surveys to ensure accurate

representation of in formation and incorporates any new developments since the previous survey. When

OGC operates in densely populated areas where risks of damage to the pipeline increase, mitigation

measures are employed. These include measures such as increasing the wall thickness, placing the

pipeline deeper into the ground, and/or construct ing more frequent Block Valve Stations (BVS).

At the NGL E site in Fahud, the pipeline crosses three regions and five prominent villages. Given the

pipeline route for the LPIC project is mostly through desert area, it is likely that it will fall under Area

Classification 1 with an increase to Class 2 or 3 as it nears Sohar . Orpic has asked OGC to confirm this

assumption and is awaiting their response. The population figures from data held by the National Centre

for Statistics and Information (NCSI) in 2014, and estimations from windshield surveys are provided in

Table 1. The population numbers are sparse, and most villages are located several kilometres away from

the pipeline route.

Table 1: Population along Pipeline

Village name Population

Al Saghah 60

Khashishat Al Melh 58

Al Jaylah 50

Al Jall 40 (estimated from site survey)

Wili 20 (estimated from site survey)

Figure 1 An example representation of an area classification of Class 3 (provided by OGC)



The closest village to the pipeline route is Al Jall, some 40 km south-east of Sohar. One of the properties

is located at 15m distance from the pipeline RoW (see left-hand property in Figure 2). Figure 3 illustrates

approximate distances from the homes and village Mosque to the pipeline (all within the 200m Zone).

Figure 2: Proximity of Residences to Existing RoW at Al Jall

Dual pipeline RoW; Buried existing pipeline; Residence of OGC driver close to Pipeline RoW

Marker; RoW marker at 25m from centreline of nearest pipeline; Wadi environment.

Figure 3: Buffer distances of houses and Mosque from Pipeline



OGC has an extensive stakeholder engagement and outreach program me to manage the potential

beneficial and adverse impacts on Affected Communities . Such engagement includes , in particular, the

people of Al Jall village. One local resident of one of the houses next to the pipeline in Al Jall is employed

at OGC. During the site visit, it was recognised that the residents have a friendly relationship with OGC

and that communication is without difficulty. OGC will take steps to minimise adverse impacts such as

disturbance and nuisance during the construction phase of the Project. Taking such proactive measures

will include avoiding construction during prayer times, hiring local people, and procuring local goods and

services from sellers and providers in the community. The duration of construction works through Al Jall

village is estimated to be short at an estimated three weeks. During this time, an HSE manager will be

available to coordinate between workers and the local villages, and ensure adherence to HSE and social

management plans. The location of Al Jall village is highlighted in Figure 4 below.

Figure 4: Al Jall Village Proximity to Pipeline

3.1.2 Sohar Industrial Area The Petrochemical Complex (PC) will be located within the well-known formal and designated existing

industrial area at Sohar. The city of Sohar is the second most populated area after the capital , Muscat. A

map illustrating the proximity of the Project to the nearest potentially Affected Communities is shown in

Figure 5.



Figure 5: Sohar Industrial Area

The area highlighted in blue is the area there the facilities will be expanded, but the local households in

that area will retain the ownership of their properties. This is discussed under the Performance Standard

5 Section of this report.

3.1.3 Potential Impacts on Local Communities in the Project Area

Construction and Operation Stages

Construction of the NGL E and PC facilities , and connecting pipeline, will create a construction corridor

where the main civil activities will take place. Based on the current design, a construction corridor will

be set around the pipeline and the NGLE and PC facilities and it is expected that the construction

activities in a given location will not take more than four to six weeks. ORPIC will be able to manage its

Contractors and third-party suppliers through the use of a Construction Environmental and Social

Management Plan (CESMP) to further minimise potential negative impacts on local communities and

avoid unnecessary delays and land take during the construction stage.

The local communities along the suggested pipeline and also close to the NGLE and PC facilities could

also be potentially affected by the proximity of workers’ camps. Based on preliminary design s, each

workers’ camp is envisaged to accommodate up to 1,000 workers (see section on PS2 for more detail).

Construction and Operation of the Pipeline

The pipeline will begin at the Fahud Site and end at the boundary of the Sohar Site covering a total

distance of about 300km. The proposed pipeline will be constructed in parallel to the existing 32” OGC

gas pipeline.

Based on the available design, the pipeline will be laid down in Sohar, in the area where the land is

mostly of industrial use and currently not used for any agricultural facilities. The proximity to the natural

gas pipeline was one of the main considerati ons aimed at reducing any potential negative impact on



local communities. The area has been historically used for industrial development, including the earlier

development of the OGC pipeline to SIPA which was finished in 2005.

Where the pipeline is closets to residential property, the history is that two households opportunistically

developed residences in close proximity to the pipeline, being fully aware about potential safety risks

but in violation of the National Law on the 25m safety zone around a ny Oil & Gas Pipeline in Oman5.

These two adjacent properties and other local settlements along the pipeline route could be affected by

the RoW required for construction. As the land required for the construction of the pipeline is

designated for industrial use, no land acquisition or changes in land usage will be made during either the

construction or operation stages. At the same time, regular communication with the two adjacent

property owners will continue, where they will be kept informed by ORPIC’s C ommunity Liaison Officers

about the schedule of works and other relevant issues. These and other residents of local communities

will have access to the ORPIC’s Grievance Mechanism. The detailed Grievance Mechanism process is

described in Annex A and will be accessible to both local residents and workers engaged on the project .

Construction and Operation of the NGLE and PC facilities

The NGLE facility will be constructed on the land which is located within Petroleum Development Oman

(PDO) Oil & Gas concession area. The Petrochemical Complex (PC) will be constructed within SIPA.

NGLE Plant

The proposed NGL E facility will require approximately 100 hectares of land within the Petroleum

Development Oman (PDO) concession area near Block Valve Stat ion 2 (BVS2) of the Government’s main

gas pipeline. Both the NGLE and PC facilities will be constructed and operated either within, or in close

proximity to, the designated industrial areas (Fahud and SIP A, respective). Therefore, no land acquisition

or changes in land usage will be involved during the construction and operation stages (for the NGLE and

PC facilities).

3.1.4 Outreach and Representation

In addition to the ongoing stakeholder consultations, in particular with institutiona l/government

agencies, OGC conducts awareness campaigns twice a year. These campaigns are directed to all

community members and minority groups including school students, elderly residents and women. The

objective of the campaign is to engage with the community, capture their concerns/grievances, and

provide updates on the project as well as re -iterate the HSE risks and precautions that need to be taken

when in proximity to the RoW.

Furthermore, OGC and Orpic facilitate regular dialogue with the Affected Communities during their daily

operations to promote effective participation during the project’s phases of development. These

outreach initiatives also allow for grievances to be raised and addressed. OGC confirmed that all

previous (i.e. prior to year 2000 when OGC assumed operational control of the pipeline) claims from the Community have been settled, and there are no active complaints from the Communities with regards

to the LPIC Project.

Orpic also has external offices within the Community, i.e., located outside the freezone/industrial area .

Therefore, no prior approval or gate pass is needed to access the office. Details of these have been

provided in the SIA Report and Stakeholder Engagement Plan (SEP) for the Project.

5 http://www.mog.gov.om/Portals /1/pdf/Oil-Gas-Law.pdf, page 10



3.1.5 Grievance Mechanism and Monitoring

As detailed in the SEP, Orpic has a robust internal and external grievance mechanism. The grievance

mechanism has been developed in an understandable, transparent and culturally appropriate manner . It

aims to “minimize the impact of activities on environment and society” .

Orpic’s formal grievance channels use a variety of engagement and communications’ techniques such as

site visits, workshops and meetings to share information and facilitate stakeholder consultations.

Community enquiries and concerns are brought to Orpic’s attention directly via the toll free Enquiries

and Complaints’ Contact Number, or raised through the Sohar Environmental Unit, Community Office,

or Visitor Centre. The complaints number is shown on Orpic’s website and through local offices.

Stakeholders who are located in remote areas or are unable to travel can raise complaints via their local

representative office (Wali or Governor) or directly to Orpic during their site visits which take place on a

monthly basis.

The EPCs and their subcontractors are expected to have internationally-compliant Grievance

Mechanisms in place prior to commencing work, as per tender requirements stipulated by Orpic. In

addition, Orpic will ensure that workers who have contractual arrangements with ORPIC’s contractors

and subcontractors could also use the same Grievance Mechanism Workers will have access to Orpic’s

Grievance Mechanism (see Annex A) through its website, and through the comments boxes on

construction camps and on site to protect anonymity. The Grievance Mechanism involves the

appropriate level of management at Orpic and methods of escalation to address concerns promptly,

using an understandable and transparent process that provides fee dback to those concerned without

any retribution. The mechanism does not impede access to other judicial or administrative remedies

available under the Omani law. Orpic will inform workers of this process at the time of hiring, for

instance in induction training.

Orpic will maintain a database to monitor grievances on a monthly basis (or more frequent if required)

during construction and operation of the LPIC Project. The database will include information on the

date, type, and resolution of grievances, as well as details on who raised the grievance and their

associated contact information. The objective is to consolidate grievances and build records to track

performance, establish trends and develop relevant operational controls over time. Furthermore, the

monitoring will provide input to the overarching social management programme which will be adjusted

as appropriate. This will also enable Orpic to better manage grievances and will also inform the

stakeholder engagement processes, preventing worker concerns escalating into grievances.

The detailed Grievance Mechanism Process with the assigned responsibilities could be found in Annex A.

3.2 Performance Standard 2: Labour and Working Conditions

3.2.1 Potential Impacts associated with workers’ influx to the Project Area

The EIA documentation and earlier SIA prepared in November 201 5 mentioned that the construction

stage alone could require up to an estimated 15,000 workers (and possibly more, perhaps up to 17,000).

Some of the workers will be Omani, but most of them are assumed to be international workers, thus

triggering project-induced influx of people to the area of the Project.



The influx of people is naturally occurring and can involve significant cross -border movement of people

motivated to enhance their quality of life, for example through greater employment opportunities and

more favourable trade and business opportunities.

Local communities could refer to international workers as ‘outsiders’ as they may not have any prior

affiliation with local communities and in the case of arriving from other countries, bring with them

different cultures, languages, religions and behaviours. In addition, if international workers are supplied

by construction workers recruitment agencies, it lays an additional respon sibility on ORPIC to manage

their labour suppliers (please see more details below on compliance with the IFC PS2 – Labour and

Working Conditions and EBRD and IFC Guidelines Workers Accommodation: Process and Standards).

International workers’ groups could include: labourers and their families, entrepreneurs/traders and

other associated groups.

This section further supplements the information contained in th e Labour Management Plan and earlier

SIA. In particular, the following is addressed:

Workforce providers and recruitment process

Workers’ accommodation.

3.2.2 Orpic’s Management of Workforce Providers and Recruitment Process

Orpic will monitor and audit the recruitment practices of contractors and subcontractors to ensure

compliance with the overarching Omani Labour Law, Orpic human resources policies and the

International Labour Organization (ILO) standards (including those not ratified yet by Oman). The

objective is to foster a strong workers-management relationship, ensuring the protection of human

rights, fair treatment of workers and providing them with safe and health working conditions.

Furthermore, the recruitment practices will be audited for bonded labo ur since it is a key concern in the

Middle East Region.

Orpic will identify international workforce and ensure they are engaged on equivalent terms and

conditions as Omani workers carrying out similar work. The Contractors will be required to base

employment relationships on the principle of equal opportunity and fair treatment, and will not

discriminate with respect to any aspect of the employment relationship. Orpic will incorporate these

requirements and those stipulated in IFC PS 2 in contractual agreements with contractors.

ORPIC will also monitor contractors and subcontractors to ensure they provide workers with

documented information that is clear and understandable, and regarding their rights under national

labour and employment (and any other guidelines), including their rights related to hours of work,

wages, overtime, compensation, and benefits upon beginning the working relationship . Orpic will also

ensure that their contractors and subcontractors do not charge international workers a “recruitment”

fee, or will at least ensure that the fees can be afforded by international workers and are not exorbitant.

By checking this issue, Orpic will ensure that the project does not associate with indebted international

labour. This also applies when any material changes occur to their employment status. All workers will

have access to the Orpic Grievance Mechanism through designated forms on site and through the

website to report or escalate any issue. Furthermore, through the longer-term monitoring programme,



Orpic will closely manage and track performance of all contractors against working conditions and terms

of employment.

In the process of monitoring their contractors and suppliers of labour/recruitment agencies , Orpic will

use a range of monitoring tools as part of its overall Environmental and Social Management System

(ESMS). These tools should not be complicated, and could involve simple and regularly maintained

database or schedules in either MS Word or Excel for ease of use and updating. Such

schedules/databases will include the following:

Human resources employee and worker database – this will track the data about employees and workers working “directly” for Orpic including wages, benefits, working hours, eligibility for

overtime etc. The database will also record useful information on the personal details of

employees (such as next of kin/emergency contact), the job description, role description and

responsibilities, training records and details of health check-ups. Such a database could be used

as a tool to monitor compliance with the Omanisation Policy through:

The number of recruited Omani nationals;

The training offered to Omani employees to demonstrate the transfer of know -how and

new skills acquired by them on the job.

Contractor, subcontractor and recruitments agencies/labour suppliers’ database – this will track the data about employees and workers working “indirectly” for Orpic including a summary

of their scope of work, the results of their HR and HSE audits, details of the origins of their

employees (local and also international workers’ details such as country, area they come from,

etc), HSE training received, Protective Personal Equipment (PP E) given, and date of fitness to

work health screening, as well as their records and results of assessments for incidents of child

and/or forced labour and significant safety issues . Orpic will monitor that the international

workers’ passports are not kept by contractors and subcontractors but instead are kept in a safe

place where workers can have access to their passports at any given time.

Worker Grievance Mechani sm/feedback system – this system will log all grievances, issues and

concerns raised by workers during meetings or formal/informal discussions (See Annex A for the

detailed Grievance Mechanism process). The system will also include areas to record

information on measures to address issues, timeframes, personnel responsible and any

subsequent feedback that is required. Please note that Grievance Mechanism will also cover

contractors and suppliers, with the Orpic Project Manager being responsible for the Grievance

Mechanism its implementation by them.

Accident and incident recording, reporting and investi gation system –this will be used to record the number and type of accidents and incidents , including near misses occurring in the

workplace both at site and in accommodation facilities . Details and the outcomes of any

required investigations along with their commensurate corrective actions will be required to

address incidents and seek the continual build-up of knowledge and lessons learned in this area .

3.2.3 Labour Accommodation

The management of impacts and risks related to workers accommodation and conditions therein, can

include the preparation and implementation of the following plans and pro cedures by Orpic:



Minimum Health & Safety Requirements List for Workers ’ Accommodation;

ORPIC Construction Emergency Response Plan for Workers ’ Accommodation;

Exposure to noise and odour should be minimised and, room/dormitory design and equipment

should offer workers a maximum of privacy. Resorting to dormitories should be minimised and

single or double rooms should be preferred;

If a contractor is used to manage workers ’ accommodation, they must have a relevant proven track record, etc.

Other best practice requirements related to the design and construction of the workers ’

accommodation can be found in the IFC Guidance Paper on the “Workers’ Accommodation: Processes

and Standards” published in 2009.

Orpic could find it easier to manage the workers ’ accommodation risks if they implement an induction

programme to be attended by all workers (including those of contractors and subcontractors) that cover

at least the following aspects:

Workers’ Accommodation rules and regulation, i.e, Workers’ Code of Conducts;

Grievance Mechanism (also accessible for workers);

Workers’ Accommodation cultural awareness (this is related to migrant workers or workers

provided by contractors or subcontractors, who are also based at the same accommodation

site);

Workers’ Accommodation health, safety and security principles.

The ECA site visit participants visited the workers’ accommodation for a nother Orpic development

project in the same area – The Sohar Re finery Improvement Project (SRIP). This was an opportunity to

observe and review the existing levels of good practice and overall management of such camps in the

vicinity of Sohar. It was agreed that the SRIP project was following many good practices in terms of

workers’ accommodation. There were some deficiencies in the SRIP labour camp including smoke

detection and fire alarms; however the SRIP camp is broadly in compliance with international standards. It is expected that the labour camps for the LPIC Project will be maintained at a higher standard than the

SRIP accommodation as adherence to the IFC and EBRD guidelines has been included by Orpic in the EPC

contracts, as well as the implementation of policies on the quality and management of the

accommodation.

Orpic will audit and monitor the camp performance, and anonymous feedback boxes will be placed in

the camps for workers to raise any grievances to Orpic (as part of the Grievance Mechanism for

Workers). Through Orpic’s workers’ accommodation monitoring programme, Orpic will verify the

provision of basic services including minimum space, supply of water, adequate sewage and garbage

disposal system, appropriate protection against hea t, cold, damp, noise, fire and disease-carrying

animals, adequate sanitary and washing facilities, ventilation, cooking and storage facilities and natural

and artificial lighting, basic medical services and fire-fighting equipment.



3.3 Performance Standard 4: Community Health, Safety and Security

This section further addresses the safety and security risks and impacts of the Project. In particular, the

following is addressed:

Emergency Response and preparedness

Security personnel.

3.3.1 Emergency Preparedness and Response

In addition to the role of Orpic’s Site Security Plan to safeguard its personnel and property through the

field construction gate on a 24-hour basis, OGC and Orpic have established an Emergency Response Plan

in collaboration with other stakeholders, such as ROP, PDO, the civil defence and ambulance services, as

well as Ibri and Nizwa Civil Defence. The main principle of the ERP is to:

1. Call emergency control

2. Checklist to categorize the type of emergency

3. Assemble the emergency response (ER) team

ROP plays an essential role in applying governmental authority to guard the SIPA along with the military

guard forces both onshore and offshore for safety and security. These forces are well equipped with

proper tools to respond immediately in the case of an operational accident occurring in order to take

preventive and control measures . All industrial security managers are directly linked to the general

command of ROP. The protection domain covers inside the SIPA and the surrounding areas to ensure

maximum protection to the port and the facilities inside and around the free zone area. ROP is also

equipped with special boats for onshore guarding (24/7). ROP has a special taskforce in the case of an

emergency situation whenever immediate and extra task forces are needed, supporting any evacuation

as required.

For the safety and security of the pipeline , OGC has implemented an integrated automated leak

detection system, exercising special care in order to avoid the potential for community exposure to

hazardous materials and substances that may be released by the project. The response time for

managing a leak is a maximum of 48 hours. To date, no significant spills or accidents have ever been

recorded at OGC.

3.3.2 Security Personnel

Security personnel are recruited from across the Sultanate, with a requirement that 80% should be from

outside the region assigned for duty in order to maintain independence from the local communities.

Although the ROP recruitment policies are confidential, reasonable inquiries were made during

consultations to verify that there are no ongoing human right issues and ensure that those providing

security are not implicated in past abuses. This was confirmed by ROP and assurance provided that it is a

non-issue. There are criteria for the selection of officers with clear requirements , including training in

Nizwa, the United Kingdom and USA. A Site Security Plan, Security Policy and Procedures, as well as a

Security Management System and Plan have been put in place (see Annex B).

ROP has confirmed that the criteria of selecting their personnel are very specific and careful selection

processes are applied, including an extensive background check. The Code of Conduct is confidential,



however they have indicated it is in line with the international standards (UN Code of Conduct for Law

Enforcement Officials). The following features are a fundamental requirement in joining the ROP:

A high school diploma as a minimum requirement;

The applicant must provide a ‘good behavioural’ certificate which is obtained from the police criminal record office to ensure that the applicant has no criminal records. While hiring Orpic

new security personnel and during the interview stages, Orpic HR Manager will check that no

candidates considered for security roles were involved in the past human rights abuses

A health certificate from a governmental medical centre to prove that the applicant is medically

fit to join;

Special medical check-up in the military hospital upon selection;

To successfully complete the basic programme for a continuous six month period.

After enrolment, there are specialised training programmes that will be provided to ROP personnel .

However, due to the confidential nature of these, only the following program mes were declared:

Heavy/light weapons usage training;

English language training;

Physical education;

Interaction and behaviour with public (mandatory);

Military talent programmes – Orion International; port area security; dedicated training

attack/defence techniques; marine attack and other security techniques;

Overseas training.

ROP closely monitors all workers and security programmes in line with applicable Omani law and

Guidelines from the General Commander. ROP confirmed that their policies are aligned with the UN

Basic Principles for the Use of Force and Firearms.

Monthly meetings are conducted by SIPC and include ROP, as well as industry safety and security

representatives to discuss all security and industrial safety related issues.

The Sultanate policy forbids ROP staff to shoot any protesters. Based on the Omani Penalty Law, if a

protester is killed by the ROP, the officer in question is subject to military court and the judicial penalty.

Historical Security Incidents

In January 20116, Regional newspaper The Gulf News reported that in late February 2011 in the

northern town of Sohar, young unskilled people protesting over the lack of local jobs started a sit-in at

the local branch of the Ministry of Manpower. They were evacuated by the police, arrested at night, and

taken to the town’s central prison. When the news spread, skirmishes developed around Sohar’s police

station and one protester was shot dead by the ROP. Sit-ins, which went on for two months, were

organised simultaneously in front of the governor’s offices in Salalah and in the eastern town of Sur.

Although these historical protests were related to the earlier development in the area as a whole, the

protests of 2011 were not related to this project which has started in 2015.

6 http://gulfnews.com/news/gulf/o man /omani-job-seekers-protest-at- muscat-roundabout-1.790942



An informal request for information among ROP personnel on the consequences of the 2011 historical

security incident confirmed that the policeman who shot the protester back in 2011 was court-

marshalled. More information on this matter was not available due to its sensitivity.

Figure 6 Orpic Meeting with ROP

3.3.3 Safety

Throughout the route of the pipeline and fencing of the industrial area, signs clearly demarcate hazards

and safety risks to the public. The Security team takes daily drives along the RoW to ensure the safety of

the community and protection of the pipeline. There are frequent and clearly marked crossing points

along the pipeline, which OGC have considered carefully based on requirements expressed by the

Affected Communities as well as the herders of goats and camels.

OGC policy is to have a Block Valve Station (BVS) at an interval of every 30km along the pipeline. The

purpose of a BVS is to contain any disasters, stopping a leak or spill from spreading; this therefore

minimizes any negative impacts, should they occur. Furthermore, a 6m inspection road, and then an

additional 25m buffer on either side of the pipeline are set for safety clearance. There are clearly

marked signs along the pipeline to warn any passers-by of the hazards and risks, as well as clear

directions of the next authorized crossing point, in addition to a contact number for any enquiries or

complaints. Figures 7, 8, 9 and 10 below are images from the site visit along the pipeline RoW.

OGC coordinates with the Ministry of Housing (MoH) for a risk-based approach when there is a need for

an extension to an existing pipeline or expansion of land close to the pipeline. The extensions and/or

expansion are only undertaken after both MoH and the Ministry of Oil & Gas grant approval in order to

ensure safety and constructability. OGC also has a modern GIS system which is updated on an annual

basis to ensure any changes that occur are reflected and integrated into their planning for HSE and

social management.



3.4 Performance Standard 5: Land Acquisition and Involuntary Resettlement

This section addresses concerns over project-related impacts on land use and livelihoods in and around

the Sohar industrial area. In particular, it addresses:

Physical Resettlement

Economic Displacement

3.4.1 Physical Resettlement

SIPA began operations in 2002 and the Sohar Free Zone was established in 2010 by Royal Decree. In

2011 and 2012, the Sultanate of Oman experienced its most widespread popular protests since the end

of the Dhofar war in the 1970s. The following were key reasons for the protests:

Newspapers reported at that time that job opportunities in the Al Batinah North area; specifically around the industrial area, were not extended to the Affected Communities.

Figure 7 Clearly marked and

available crossing points on pipeline

Figure 8 Clearly visible signage along the pipeline

Figure 9 BVS signage Figure 10 BVS using solar panels.



Protesters called on the Sultan to personally intervene to end the reign of wa sṭa (social

intermediation) and favouritism in the public sector and to put on trial long -serving ministers

widely perceived as embodying corruption.

The protests were managed by the government and the Sultan issued the following remedial solutions:

Minimum wage increased by 40%.

Monthly unemployment allowance of Omani Rials (RO) 150 (for job seekers registered with the

ministry of manpower) was introduced.

Dismissal of ten Ministers (largest re-organisation in 40 years); three were replaced by Batinah locals.

Development of the Consultative Council (Majlis AL Shura).

Establishment of “Liwa City”.

Royal Decree (RD 52/2013, see Annex C) is the official Royal decision for the establishment of the ‘Liwa

City’ project. The project is fully financed by the government and aims to provide alternative housing for

residents and Affected Communities around SIPA and the Free Zone. This resettlement was seen as a

solution and it is considered voluntary as the residents requested moving and increase of minimum

wage during the uprising.

The Government allowed the residents to keep their land, where they could lease their land thereby

benefitting from the industrial development and lease income. No previous resettlement took place in

the Sohar port area and the resettlement of people under the Liwa City development will take place in

one phase.

While a series of strategic studies and plans have been conducted for the project (as verified during the consultations with the Governor) they are not publically available and remain inaccessible to Orpic. In

discussions with the Ministry of Environment and Climate affairs, Orpic confirmed that a committee was

set up at the highest level to plan and implement the Liwa City development in consultation with all

responsible parties. This committee involved the Ministry of Housing, Local Governors and Walis,

Ministry of Municipality and the Ministry of Environment.

This LPIC project does not relate to the Liwa City resettlement or any future resettlement plans . Figure

11 is an illustration from the Royal Decree which has been marked to show the port area, villages and

where they will be moved.



Figure 11: Liwa City (Image from RD 52/2013)

3.4.2 Economic Displacement

The impacts on livelihoods and standards of living are widely considered to be positive in the Sohar and

Liwa area. The Ministry of Agriculture and Fisheries place great importance to the construction of fishing

infrastructure to provide better services to the fisherman and promote the development of the fishing

sector in Oman. As such, the construction of fishing jetty is underway to benefit the fishing community

in the Wilayat of Liwa. The jetty will be able to accommodate about 80 fishing boats and 10 multi -

purpose vessels. This will add to the 12 fishing ports a cross the Sultanate’s coast. The facilities and services that will be provided to the fishermen include a gas station, ice factory and workshop for the

maintenance of fishing boats. It should also be noted that the Liwa City project occurred before the

project and impacts are not induced by the project.

Furthermore, social impacts on Al Jall village and traditional livelihoods along the pipeline route are

adequately addressed by OGC social management and outreach programmes described in earlier

sections of the report.

Goats and camels were observed during the site visit to the pipeline (see Figure 12), and it is clear that

their passage will not be impacted during construction, commissioning and operation, as the herds can

freely cross the pipeline and hence will not be affected by the operational activities of OGC. As described

in earlier sections of this report, there are clearly marked hazard signs and frequent crossing points for

herders along the pipeline. Through regular outreach with the community, OGC also provides additional

crossing points (free of charge) to Affected People as requested by them or needed.



Figure 12 Goats and domestic animals noted along the pipeline right-of-way

As illustrated in Figure 3 in earlier sections of this report, the mosque in Al Jall village is over 35m away

from the pipeline and will not be affected by the project. In fact, the mosque will contribute to the

societal cohesion in the project area, where the locals and the Muslim workers will be able to visit the

mosque during prayer times. The houses in close proximity to the pipeline will have access to ORPIC’s

grievance mechanism and ORPIC’s community liaison officer will keep the property owners infor med

about any development or potential works in the future. Figure 13 includes images from the site visit to

the Al Jall Village.

Figure 13 Al Jall Village



3.5 Performance Standard 7: Indigenous Peoples

This section addresses Bedouins as Indigenous People located around the Project area. It supplements

the information provided in the SIA on the socio-economic baseline and history of Bedouins in Oman.

Based on the IFC Performance Standard 7 Guidance (para 5), certain criteria are used to determine

whether a tribe falls under the “indigenous people” category, particularly where they meet most of the

four criteria:

1. If a tribe self-identifies as members of a distinct indigenous cultural group and th ey are

recognised by others as such. N.B. Supported by UNESCO, in 2012 Oman signed th e commitment

on Intangible Cultural Heritage of Humanity aimed at preserving and protecting the Bedouins’

poetry and folklore stories.

2. If a tribe has a collective and historical attachment to the land in the project area . The Bedouins

have lived in the wider project area for centuries and occasionally use the appropriate land for

communal grazing of their camels ;

3. If a tribe has separate (cultural, economic, social or political) institutions that are separate from

the mainstream; and/or

4. If a tribe has a distinct language from the rest of the country. In Oman, although the Bedouins

speak the same language, there are substantial differences between Bedouin and typical Arab

language speech used by “sedentary” people in Oman.

It is clear that Bedouins meet most of the above criteria, and therefore are recognised as Indigenous

People.

Although Bedouins in the project area have their own distinctive way of life, their livelihoods are very

unlikely to be affected by the project due to the following:

1. The pipeline design envisaged several crossing points along the pipeline route (see images

below) and

2. Their cattle will be able to easily cross the pipeline terrain.



Figure 14: Pipeline crossing points (images from site visits and satellite image of a 4KM stretch of the pipeline)

It must be noted that any potential impacts will be temporary (as most will occur during the

construction) and a proposed construction period will last only four to six weeks at any given location.

To address and mitigate any unforeseen or unpredicted impacts in the future, the ORPIC’s Community

Liaison Officer (CL O) will routinely visit the Bedouins locations to check if they have any

recommendations or concerns, and will promote the Grievance Mechanism that will be established by

Orpic and accessible for all parties. In addition, every six months a site visit and monitoring review of the

existing properties in the area and the pipeline itself will be undertaken by ORPIC’s specialists.

OGC currently has a total of ten Bedouins working in employment for them; four have been trained as

inspectors and technicians, and six are drivers and security guards.



Based on regular dialogue and communication with Bedouins , which will continue in the future, any

potential impacts will be noted and mitigated in consultations wit h them. This will help to avoid any

negative impacts on their livelihood and cultural heritage.

3.6 Performance Standard 8: Cultural Heritage

This section addresses the comment raised during early project consultations with Affected People.

During Orpic’s consultations with the locals and Wali at Khasishat Al Melh village, a member of the

community mentioned the nearby grave wall and asked ORPIC’s assistance in the routine “maintenance

of the Khashishat AL-Melh Village Cemetery Wall.” Following this discussion, Orpic conducted additional

site visits to determine the location of the grave wall and its distance from the pipeline.

The existing cemetery is located 600m away from the project area and Orpic dispatched its team to visit

the site on the 21st of December in order to verify its location and assess potential impacts. The

cemetery itself and its walls were found to be in very good condition, and all the walls remain intact. The

site is located 600m away from the existing pipeline in Khashishat Almelh area. There will be no impact

on the cemetery from by the LPIC project. Affected Communities have been met with and consulted

regarding this site, and they have confirmed that the grave site and wall i s the only one in the area, and

that it is in good condition, and have not been impacted by the Project. Images in Figure 15 illustrate the

location and condition of the cemetery walls.

Any unidentified potential impacts on cultural heritage will be further assessed and managed through

the Construction Environmental and Social Management Plan (CESMP) and its Chance Find Procedure.



Figure 15: Kashishat AL Melh Cemetery

Grave site Grave wall



4. Recommendations

This is the Supplementary SIA Report that was requested by Lenders . Orpic and its advisor have made

significant efforts to provide additional information and complete the previously identified gaps.

The visit to the project area was very useful for asc ertaining the nature and the scale of potential

impacts.

Taking the project forward and planning for future monitoring, the following recommendations are put

forward to demonstrate Orpic’s commitment to compliance with the 2012 IFC Performance Standards,

Equator Principles (EPIII, 2013) and best practice:

1. Condition to first disbursement, ORPIC will carry out a socio-economic survey in the Project area

on the basis of an informal interview at the household level, collecting the following data:

Project community-specific social and economic baseline information.

Baseline data for existing health issues and conditions within local communities .

Information regarding the use of land by households and households’ livelihood (i.e. sources

of income) in the project area (how the land is used, e.g., for growing food/vegetables, raising

cattle/grazing or for other purposes, etc.).

The collected socio-economic and health data will help ORPIC and Lenders to :

Determine the baseline socio-economic conditions prior to the first drawdown and monitor them throughout the life of the project, including: demographic profile (age, gender, family

structure), housing conditions and distribution of settlements, occupational profile, including

employment and livelihood status (i.e. jobs, sources of income, livelihood strategies, income

profile, education, etc

Monitor key performance indicators to ascertain how the project is impacting on local

communities’ lives and health. The local communities’ health data will cover questions about

the existing health issues among local communities, such as:

Accidents and injuries – particularly caused by road traffic and community proximity to construction sites, and any spills and releases to the environment.

Non-communicable diseases (e.g. high blood pressure, allergies, respiratory infections, etc .).

Vector-borne diseases.

2. Based on an independent scope of work for monitoring social program mes and management

systems, Orpic will establish a social monitoring programme during construction and operation

stages and seek international experts to provide training on best practices (see details below on suggested Social Monitoring System).

3. Orpic will carry out regular site visits in addition to their desk-top reviews every six months to

verify/review social programmes and management systems.

Social Monitoring

Orpic’s Community Liaison Officers (CL O) and counterpart in every contractor/subcontractor

organisation will maintain a regular dialogue with local communities during the construction and



operation stages, and will keep monitoring the socio-economic and health key performance indicators

(KPIs) among local communities once a year for reporting purposes .

All contractor/subcontractor personnel interacting with local communities’ members will submit weekly

reports on their activities to the Orpic’s CLO. All contractors/subcontractors associated with the Project

will promote and follow the same Grievance Mechanism Procedure operated by Orpic (Annex A).

All registered grievances related to Orpic’s contractors/subcontractors will be jointly investigated by the

sub-contractors’ relevant Officer and Orpic’s CLO.

All contractors/subcontractors will immediately submit a report to Orpic after any social ‘incident’

(including complaints or concerns received from communities) which will identify the causes and make

recommendations for mitigation and improvement.



Appendix A: Orpic Grievance Mechanism Process

Principles and Overview

Based on the IFC Performance Standard 1 (PS1, Assessment and Management of E&S Risks and Impacts)

and Performance Standard 2 (PS2, Labour and Working Conditions) as well as Equator Principles

Principle 6 (Grievance Mechanism), a “Grievance Mechanism” (GM) for the project is a re quirement.

Initially, Orpic developed a GM tailored to the risks and predicted impacts of the Project and with local

communities and workers (including third party/sub-contractors’ workers) as its primary users.

The process detailed below seeks to improve and enhance the GM by resolving concerns promptly,

using a simple, transparent and culturally appropriate consultative process, at no cost. It should be

noted that the GM does not prevent a third party from acces sing the national judicial or administrative

process.

To manage grievances and complaints based on best international practice, ORPIC will implement the

following principles:

Documentation & Tracking: Any new grievance will be registered (i.e. documented), receipt acknowledged within three calendar days of its receipt and a response including proposed

solution/resolution made within ten calendar days of its receipt. It will be tracked until it is

closed

Two-tier re solution: The management of the GM will include two successive tiers of amicable

grievance review and resolution, i.e.,

o at first, the complaint will be addressed, internally, by ORPIC. I f the complainant is not

satisfied with the proposed solution, then;

o a second-tier will involve the consideration of the grievance by a Grievance Review

Committee (GRC) – see below;

National law: In cases where the complainant (or group) is not satisfied with the outcome

proposed by the above mechanism, they will be able to pursue the issue through the Omani Judicial System and Courts at any stage in the resolution process.

The Grievance Review Committee (GRC) will be set-up by ORPIC and involve the participation of other

parties such as OGC (the operator of the pipeline) and representatives of the local Wali’/authorities’ to

address second-tier complaints arising as a result o f the implementation of the project. The GRC will

consist of at least one woman to ensure a gender-inclusive assessment of, and approach to, future

complaints and grievances from both women and men. The GRC’s main role will be to check that all

complaints/grievances that were received in writing (or written down when received verbally) and

addressed within the first 10 calendar days from the day upon which the grievance was received and

registered on the system.

ORPIC will inform the local communities, its workers and sub-contractors’ workers about the Grievance

Mechanism and provide (e.g. on posters) contact details outlining how complaint can be reported to.

Such information needs to include:

A Community Liaison Officer – to whom a complaint can be made verbally;

Telephone number;

Email address; and/or

Addressee and address to which a letter can be delivered to.



All contact details and means of submitting a complaint will be widely and r egularly publicised,

throughout the duration of the project. This might be through posters at key locations (e.g. outside a

local market), advertisements in local papers/on the radio and verbally by ORPIC employees.

For local communities, the GM contact details will be provided on posters in Arabic in locations

prominent to the local population and also orally during consultation activities with local Bedouins (in a

dialect used by Bedouins) and other focus groups.

Details of the Grievance Process

The process for responding to grievances is presented below.

Receipt of Grievance

The GM will include a variety of means by which a grievance can be submitted which may include face -

to-face meetings, by telephone, by post, electronically, and using a suggesti on box. Please see Annex C

for a Sample Grievance Form.

For reasons of confidentiality and to protect the safety and security of ORPIC personnel, the

contact details of individual staff members will not be released to external

parties/complainants.

Grievances will be reported immediately and directly – by the person who initially received the grievance – to a Community Liaison Officer (CLO) or an HSE Officer in the first instance.

Recording of Grievance

The details of each grievance will be recorded in the Grievance database.

In the case of receiving grievances via a suggestion box, a CLO will open the box on a frequent

(e.g. weekly) basis and collect the grievances that have been submitted. The original copy of the

grievance will be retained on file by the CLO.

Acknowledgement of Grievance

The ORPIC Management will assign a CLO to manage the grievance.

On the basis of the nature and potential seriousness of the grievance, the CLO will determine who will communicate with the complainant (in most case s it will be the CLO if considered

appropriate).

During the routine visits to the project area by the CL O, the complainant will be contacted

within three days to verbally acknowledge that his/her complaint has been received and to

inform them of the likely timeframe in which a follow-up action can be expected.

Eligibility Assessment and Decision-Making

The grievance will be reviewed by the CLO and ORPIC Management to determine if it is eligible

for further consideration.

The CLO assigned to the case will aim to obtain as much background information as possible in conversation with the complainant, to enable the ORPIC Management to make a decision

whether to proceed with the grievance.



In relation to a grievance that concerns physical damage (e.g. damage to a wall), photographs of

the damage will be taken in presence of the complainant/affected party and/or officials and the

exact location recorded as accurately as possible.

The findings of the all investigations will be entered into the grievance file and u sed to determine eligibility.

A grievance will be classified as ‘eligible’ if it is directly or indirectly caused by the LPIC project.

A grievance will be classified as ‘ineligible’ if it is clearly not related to the project.

Formal Communication with a Complainant

If the Grievance is considered to be ineligible, the CLO will contact the complainant within three working days and explain that the complaint was not recognised as eligible.

The Grievance file will be updated with a full explanation and the re asons why it was considered

ineligible and the case will be formally closed.

In the case of eligible grievance, the complainant will be contacted within three working days from the date the complaint was received to formally acknowledge the grievance and o utline

the process that will be followed. The contact will be made by the CLO or other authorised

person.

Assessment of Significance of Feedback or Grievance

Eligible grievances will be reviewed to determine their significance using the criteria below (Table 1).

If necessary, the complainant will be contacted for more information, and a site visit may be

undertaken.

Witness statements will be taken if necessary.

Once additional information has been gathered, the CLO will review (and revise as necessary)

the significance rating.

Table 1 – Grievances Significance Criteria

Significance

Level

Type of Grievance/definition Other parties to be

involved

Level 1 A grievance that is ‘one-off’ and essentially local in nature

and restricted to one complainant. Please note that some

one-off grievances may be significant enough to be

assessed as a Level 4 grievance.

CLO and other relevant

ORPIC manager(s) as

appropriate

Level 2 A grievance that extends to the local community and has

occurred more than once, which is judged to have the

potential to cause disruption to ORPIC operations or to

generate negative comment from local media or other

local parties.

CLO, Site Manager and

relevant ORPIC manager(s)

Level 3 A grievance which is widespread and repeated or has

resulted in long term damage and/or has led to negative

comment from local media, or has resulted in a serious

breach of ORPIC policies, Omani or International Law

and/or has led to negative national/international media

attention (e.g. damage to a local cemetery).

CLO, Site Manager,

Operations Manager,

ORPIC Director/CEO and

Lenders



Decision on actions to address a Grievance

The initial step will be for the CLO to report the grievance to the Site Manager or HSE Manager

who will determine whether it can be resolved immediately without further investigation.

The actions to address the grievance will be determined in consultation with the complainant.

The proposed actions will be reviewed and approved by the relevant ORPIC Manager.

The complainant will be informed about the proposed action and the expected timeframe for

resolution of the grievance.

The complainant will be asked to formally agree to the proposed remedial actions that are proposed.

The Grievance file will be updated with new information with rega rds to the actions agreed to

be taken to address the grievance.

Actions Taken to Resolve Grievance

Progress against the grievance action plan will be monitored by the CLO.

CLO will liaise with the complainant during this process and also when the grievanc e has been addressed to ensure the complainant is kept informed about progress and to discuss any issues

or concerns.

“Closure” of the Grievance

Once the grievance has been addressed the complainant will be asked to formally acknowledge that the actions have successfully resolved the grievance.

Verbal acknowledgements will be independently witnessed and recorded on the grievance file.

If the complainant is unwilling to accept that the issue has been successfully resolved, the case will be referred to the Grievance Review Committee (GRC) for follow-up action to be taken as

appropriate.

Once the resolution of the grievance has been accepted by the complainant, the Grievance file

will be updated and the case will be formally “closed”.

The GRC will cover grievances which were not possible to resolve at the first tier level. During their

regular monthly meetings, GRC will propose their solutions to the unresolved grievances. These

solutions, if agreed by the complainant, will be binding and final for both ORPIC and the complainant(s).

The objective of the GM at the second tier is to avoid project delays and to reach amicable settlements

wherever possible. No grievance should be considered by the GRC unless it has been through the first

tier.

If necessary, the GRC will involve an external party (i.e. local Wali) who will be acting as mediator and

selected based on the following criteria:

Not connected to ORPIC in any way;

Experience in addressing disputes and resolving disputes and/or mediation .

The External Party/Mediator will review grievances with the GRC members and aim to suggest the most

agreeable solutions. Once these solutions are preliminary identified as “possible solution”, they will be

reviewed by ORPIC, for final agreement. Minutes of meetings, including proposed solutions, records of

decisions and agreements reached, will be prepared and logged into the grievance file.



Where the settlement cannot be reached even at the second -tier, after the GRC and external parties’

involvement, either the complainant or ORPIC can take the dispute to the national judicial system/Court.

Ongoing Monitoring and Evaluation

ORPIC will conduct ongoing monitoring to ensure that grievances are managed in accordance with the requirements of this procedure.

Individual grievances and associated documentation will be reviewed frequently to evaluate

progress in addressing specific issues, measure success, and identify opportunities for further

action to be taken as required.

Monitoring will identify any problems and successes so that corrective action can be taken.

Monitoring will be fully integrated into the overall project management process.

The Grievance file will be monitored regularly (internally and externally by an independent

consultant) for recurring grievances so that appropriate mitigation can be developed.

ORPIC’s lenders will be provided with regular reports to demonstrate how the GM is working, clarify its purpose, and monitor its implementation.

Table 2 – Key Performance Indicators for monitoring Grievance Mechanism Management

Indicator / Issue

Measured through Frequency of internal

monitoring and

external reporting

Average time to process and

close a grievance

Measure time interval between grievance

registration and closure and time

between grievance registration and first

acknowledgement of receipt

Quarterly

Number of open grievances

over time

Grievance Database Quarterly

Number of grievances opened

in each quarter and over time


Number of grievances

successfully closed in each

quarter and over time


Monitoring & Evaluation

Monitoring and evaluation will include a review of internal and external monitoring and reporting

procedures to ascertain whether the project is being carried out in compliance with the IFC PSs Policies

and Equator Principles (version III) Principles 7 and 10; also, a review of monitoring records as a basis for

identifying any potential areas of non-compliance or any recurrent problems.

The grievance records will be reviewed for evidence of significant non -compliance or recurrent poor

performance in grievance management.



Roles and Responsibilities

ORPIC will ensure that roles and responsibilities for implementing and complying with this GM process

are allocated and been made available. Key responsibilities of the staff who will be involved in the GM

will be included in their job descriptions and/or other appropriate documentation.

The CLO will be primarily responsible for coordinating the GM in relation to external complainants. The

responsibilities and accountabilities for GM implementation by ORPIC’s corporate and site -related staff

are summarised below.

Corporate Level Responsibilities and Accountabilities

The Project Director or Operations Manager will have accountability for:

Making available the necessary resources for this GM to be effectively implemented including a

dedicated budget for resourcing it and addressing eligible grievances through financial or in -kind

compensation, where appropriate.

Ensuring that necessary resources are allocated and used in a fair and transparent manner for the management of the GM .

Ensuring all financial and in-kind compensation for grievances is: (a) transparent, (b) recorded

and counter-witnessed and (c) made in accordance with ORPIC’s Code of Business Conduct

Policy.

Ensuring that the process of this GM is followed by all project -related activities and ORPIC

departments.

Maintaining positive relationships with all local communities and other key parties (including

sub-contractors) through regular communication, consultation and engagement.

Communication between ORPIC and its contractors/subcontractors with clearly defined

arrangements and responsibilities for recording, reporting and responding t o grievances.

The satisfactory resolution of grievances which have the potential to impact on the project.

Overseeing the investigation of grievances and the agreement or disagreement of the suggested

corrective actions.

Training related to the GM implementation.

The setting-up and maintenance of an auditable GM database for receipt, recording and

tracking of the grievance.

Monitoring and improving the GM process to maintain positive relationships with the local

communities and other involved parties.

Site Level Responsibilities and Accountabilities

A Site Manager (or an HSE Manager) has responsibility for:

Supporting key ORPIC staff with regards to managing grievances in an effective and efficient

manner.

Ensuring that the GM is first implemented at the first-tier internally.

Reporting to ORPIC senior management any potentially significant grievances that have the

capacity to escalate.

Working with the CLO to better understand the main issues that have been raised.



Ensuring the consistent implementation of the GM.

Supervising the CLO and their grievance coordinating responsibilities.

Where necessary, interacting with local complainants, in particular local communities on behalf

of ORPIC.

All ORPIC personnel and contractors/subcontractors:

All Orpic staff, contractors and sub-consultants need to:

Report immediately to the CLO any grievance made directly to them by a member of the

community or a worker employed by them.

Participating and co-operating without prejudice in the investigation of grievances as r equired

depending on the nature and severity of the grievance.





Appendix B: Site Security Plan

PDF Attachment



Appendix C: Royal Decree 52/2013

• Article 1: Declares the

construction of housing units in

the wilayat of Liwa project

specified in the attached memo

and total diagram among public

utility projects.

• Article 2: The authorities

concerned shall expropriate,

through direct implementation,

the properties, relevant land

needed for the aforesaid

project, as well as installations

over them, in accordance with

the provisions of the Public

Utility Expropriation Law.

• Article 3: The Decree comes into force from its date of issue.

Documents

Liwa Plastic Industries’ Complex - Orpic Project_Supplementary... · Liwa Plastic Industries’ Complex Additional Environmental & Social Information for Lenders Supplementary Social